Voluntary Compliance – A Pre-Enforcement Framework for Healthy Housing Dale Hagen Alameda County Healthy Homes Department

Basics of Voluntary Compliance Assessment and Documentation Owner Notification and Engagement Technical Advisement Compliance Monitoring

Why Try Voluntary Compliance 1.To get something done when –Enforcement is not an option –Enforcement is not the first option –Enforcement is not the best option

Why Try Voluntary Compliance 2.Give owners a chance to fix problems 3.Engage both parties-Tenants and Owners 4.Due diligence before reaching for enforcement help 5.Document Patterns of Behavior and Non-Responsiveness

Why Try Voluntary Compliance 5.Document the need and extent of the problem - Type of Problem - Geographic Area 6.Gather information on impact of problem on families and vulnerable populations

Lead Poisoned Children Unsafe Renovations (Lead) Advancing Safe and Healthy Housing for Children and Families (ASHHI) Mold Voluntary Compliance in Alameda County Programs

Lead

Voluntary Compliance: How We Got Started Alameda County Lead Poisoning Prevention Program –Public Health Nursing –Environmental Health Specialists –Outreach and Education Team –Housing Professionals –Enforcement through Environmental Health

Case Review Working Group –Interdisciplinary Meetings –Technical Assistance –Compliance Monitoring Voluntary Compliance: How We Got Started

Technical Advisement and Compliance Monitoring Notify and establish deadlines Assigned Housing Specialist Persistent follow-up Interdisciplinary Review

Initially: –Enforcement referrals limited –Lengthy process 2000 Median: 224 days to closure Median: 88 days to closure –Enforcement referrals ~1-2 per year Impact-Lead Hazards

Based on resources available –Triage by level of presumed hazard Voluntary compliance model –Owner notification w/deadlines –Technical advisement –Compliance monitoring Interdisciplinary Team review Next Step: Expansion of EBL Response

Actions/Services Parent NotificationXXX Services/ReferralsXXX Home VisitXX Nursing Case ManagementX Environmental InvestigationX Visual Survey X Technical AdvisementX x Compliance MonitoringX x Enforcement ReferralX x EBL Response-Triaged

Voluntary Compliance Elements Intake and Assessment On-Site Assessment Owner Engagement Technical Advisement and Compliance Monitoring Enforcement Referral –Where available and appropriate

Owner Engagement Notification Connect to Health and Codes Promote Urgency or Deadline Offer Assistance

Voluntary Compliance-What Will You Do? TRIAGE: Engagement Criteria –What will you respond to? Response Criteria –How will you respond (level of resources) Closure Criteria –How will you know when you are done?

Developing Criteria: Engagement Criteria and Level of Response Available Resources and Services Severity –Extent –Immediacy Vulnerable Populations –Lead: Children, child-care, school, EBL –Mold: Asthmatic or respiratory distress

What Will You Do? Response Options Advice Notification and Technical Assistance Site Assessment and Documentation Compliance Monitoring Enforcement Referrals

Assessment Criteria Visual or Testing? –Lead: EBL 15+: EnvironmentalTest EBL 7-14: Home VisitVisual-Presume Unsafe Renovation:Visual-Presume –Mold: Visual

Unsafe Renovation (Lead)

Review- Voluntary Compliance Elements Intake and Assessment On-Site Assessment Owner Engagement Technical Advisement and Compliance Monitoring Enforcement Referral –Where available and appropriate

Initial Inquiry/Complaint Intake –Gather information –Provide advice, response options Assess –Active –Severity Research Phone calls-renovator and owner Site Visit?

Site Assessment

Owner Notification Why we are involved & -lead safety codes -Assessment Findings -Problem/Health Impact -Requirements / Consequences -Offer of Assistance -Timeframe for response

Standards: State Law EPA RRP (where applicable)

Work Practices Improvement

Closure Time Periods FY 10FY 12 # of incidents Closed within: 30 days 31% 34% 60 days 37% 53% 90 days 49% 73%

Advancing Safe and Healthy Housing for Families and Children Assessment Family Interview Basic Environmental Treatment Owner Notification and Engagement –Letter –Scheduled Appointment –Follow-up for 3 months Enforcement Support-Oakland HH Pilot

Standards: HHRS 29 Hazards

Housing Health and Safety Assessment Report Assessment date, type and disclaimer Verify/Correct by qualified person HHD available for consultation

Housing Health and Safety Assessment Report Deficiency Location Health Risk Recommended Correction

Oakland Healthy Homes Pilot Project Oakland –Building Services –Housing Assistance Center Alameda County –Healthy Homes –Asthma Start –Place Matters Community/Tenant Groups Also: Legal Aid, Vector Control, Health Care

Results Project% w/ownerOwner $ repairsAvg./unit HUD FY09 HH26%$1,115 ASHHI49%$ 680

Further Evaluation Most serious repairs addressed? Type, extent and severity of unaddressed items? Longer term impact? Resources required.

Mold Phone Consults Gathering Information Referral to building department –Advice about effective complaint Moisture, water intrusion, water leak Don’t say “mold”

Standards: Public Health Department Statements

Gather Information Mold Calls July 2012-June 2013 Alameda 5 Albany 0 Berkeley 6 Dublin 0 Emeryville 0 Fremont 1 Hayward 4 Livermore 0 Newark 0 Oakland 29 Piedmont 0 Pleasanton 0 San Leandro 10 Union City 0 Unincorporated Castro Valley 2 San Lorenzo 4 Total 61 July 0 August 2 September 0 October 4 November 3 December 2 January 11 February 11 March 8 April 11 May 6 June 3

Mold Next Steps-

Challenges and Barriers Managing Expectations –You can’t make everyone happy –People hear what they want to hear –Be clear to yourself about what you will do –Deliver clear messages about expectations –Provide referrals to enforcement agencies

Challenges and Barriers Larger Conflicts –Maintain fair and neutral stance –Referral to: Mediation Legal Aid Tenant or Rental Owner organizations

Measures of Efficacy Anecdotal Median Days to Closure Compliance at: –Initial Visit –2 nd Visit Owner Contribution - %, $ Year over year changes in compliance Compliance difference when RRP certified?

Works Better With: Commitment to the process –Interdisciplinary Collaboration Willingness to start without all the answers Housing/Health/Outreach expertise/partners Link corrective actions to existing standards

Works Better With: Standard Process Good Documentation Referral Network Resources

Skills Listening, Communicating and Educating Mediation Housing Assessment Health Connection Develop collaborative relationships

Review-Voluntary Compliance Model Triaged Response On-Site Assessment Owner Engagement Technical Advisement and Compliance Monitoring Enforcement Referral –Where available and appropriate

Alameda County Healthy Homes Department Community Development Agency Please complete the evaluation form Thank You!